1. Who is responsible?
Orange-Express, operating FreshIntel, is the controller. Orange-Express is a Dutch sole proprietorship registered with the Chamber of Commerce under number 73179442 and VAT number NL002450382B70. Registered business address: T Routje 14, 6024 BP Budel-Dorplein, the Netherlands.
2. What information do we process?
We process only information relevant to providing and securing FreshIntel.
- Business contact details, role, company, country, language and communication preferences.
- Account, access, consent, subscription, invoice and security records. Payment credentials are handled by Mollie and are not received by FreshIntel.
- Messages, support requests, Data Partner and pilot applications and meeting notes.
- Technical information such as IP address, timestamps, browser or device data and audit logs.
- Optional visitor measurement after consent: pages, fixed actions, country/region, device category and referral domain. A code derived from IP address and browser recognises daily visits and half-hour sessions. This is pseudonymous, not fully anonymous. The event table stores neither raw IP addresses nor full user-agent strings.
- Authorised Data Partner submissions, provenance, permissions and quality records. Do not provide unnecessary personal information about third parties.
- Usage and preference signals used to make the experience relevant to a user’s role, products, regions and destinations.
- Questions entered in Ask FreshIntel. When AI interpretation is enabled, the question text may be processed by Anthropic’s Claude API; customer identity and raw market rows are not sent with it.
3. Why and on what basis?
Accounts, trials, subscriptions, billing, support and requested AI answers: contract or steps requested before a contract (GDPR Article 6(1)(b)). Where applicable, business contact details are processed for our legitimate interest in maintaining the business relationship (Article 6(1)(f)).
Invoices and tax records: legal obligation (Article 6(1)(c)).
Access security, abuse prevention and specific disputes: legitimate interest in safe services and protecting our rights, limited to necessary data (Article 6(1)(f)).
Optional visitor measurement: consent (Article 6(1)(a)). Accepting and rejecting are equally easy. Withdraw via Privacy settings without losing access. Your choice is stored locally for 180 days. Do Not Track and Global Privacy Control disable measurement.
Requested introductions and Data Partner services use the contact details necessary for that service. External disclosure of contact details and reuse of contributions follow the separate choices in the service. Analytics consent is not required for a subscription.
3A. Account-sale data has separate purposes
A private importer check and a lot-list account-sale proposal are processed only to return that customer’s result. They are not realised-price observations and are not used to train or improve shared price models.
A definitive account sale already received by a supplier can be contributed through the separate contribution flow. The raw document is read locally where supported; FreshIntel receives the confirmed normalised values, a document hash, a format fingerprint and permission records, not supplier or customer names. A contribution remains excluded from models until human review confirms source, unit, currency and commercial basis. Model training, production inference, aggregated derivatives and parser improvement each require an explicit permission in that flow. Accepted observations remain labelled as realised transactions and are only shown externally with appropriate aggregation, delay or suppression.
4. Personalisation and automated processing
FreshIntel may rank prices, risks, forecasts and news using role, product, region, destination and prior interactions. This reduces noise and surfaces relevant commercial information. It is not used to make a decision with legal or similarly significant effects about an individual without appropriate human involvement.
5. Sharing and international transfers
Providers include Mollie (payments and invoices), OpenAI/ChatGPT Sites and Cloudflare (site and sign-in), Vercel (freshintel.nl) and Supabase (data services and analytics; primary project region Germany). When AI interpretation is enabled, Anthropic processes question text. Do not include unnecessary personal data or third-party confidential information. Hosting and authentication providers receive the technical data needed to deliver their services.
International providers may process data outside the European Economic Area. A valid GDPR transfer mechanism is required, such as an applicable adequacy decision or standard contractual clauses, with supplementary safeguards where necessary. Request details of recipients and applicable transfer safeguards at partners@freshintel.nl. We do not sell personal data or publish contact details as market intelligence.
6. Retention and security
Central visitor events: 395 days, followed by daily automatic cleanup. Analytics rate-limit counters are cleaned up after 48 hours. Daily totals without visitor or session codes may be kept longer for historical statistics. The local privacy preference expires after 180 days.
Account and subscription records: while needed to manage your account, access, contract and outstanding obligations. On a deletion request, we separately assess records needed for tax retention or a specific dispute; these are not used for visitor measurement. Invoices and basic tax records are generally kept for seven years from the end of the relevant financial year.
Support, introduction and Data Partner files: during handling and while needed to evidence agreements, consent or source rights. Closed files are retained only for such demonstrable obligations or a specific dispute. Contact us for deletion or the retention period of your file.
Ask FreshIntel does not store question text in visitor statistics. The external AI provider used to answer questions may apply its own technical retention periods. Access to stored data is restricted, with encrypted connections and appropriate access controls.
7. Your rights
You may request access, rectification, deletion, restriction or portability; object to processing based on legitimate interests; and withdraw consent without affecting prior lawful processing. You may object to direct marketing at any time.
Contact partners@freshintel.nl. We normally respond within one month. Complex requests may require up to two additional months; we will explain this within the first month. We request only necessary identity-verification information. You may complain to the Dutch Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl) or your competent supervisory authority.
8. Contact and changes
Send privacy requests to partners@freshintel.nl. Material changes will appear here with a new effective date. Where required, we will provide a separate notice or request fresh consent.